Every contractor registered in the Dubai Contractor Register operates under 18 specific obligations set out in Article 15 of Dubai Law No. 7 of 2025. Together they form the operating manual for lawful contracting practice in the Emirate — what you must do, what you must not do, who you must notify, what you must keep, and for how long. Breach of any one of them is enforceable under the Article 22 penalty regime, with fines from AED 1,000 to AED 200,000 plus additional administrative measures up to and including Register removal. This guide walks through all 18 obligations, groups them into practical themes, anchors each to its sub-paragraph in the Gazette, and explains how they interact with the Article 14 classification framework, the Article 17 subcontracting rules, the Article 22 penalty schedule, and the 8 January 2027 regularisation deadline.
All references in this guide are to Dubai Official Gazette No. 726/59, published 8 July 2025, which contains the full Arabic legal text of Law No. 7 of 2025. The Law came into force on 8 January 2026 (Article 29). Article 15 applies from that effective date to every contractor registered in the Emirate, regardless of regularisation status under Article 26(a). For a structured self-audit of your current position against each of the 18 obligations, use the free Dubai Contractor Compliance Checklist.
Why Article 15 is the operating manual for every Dubai contractor
Three reasons make Article 15 the most consequential provision of Law No. 7 for day-to-day operational compliance:
- It is the bridge between registration and enforcement. Articles 11 to 14 govern how a contractor gets onto the Register and is classified; Article 22 governs what happens when they breach the Law. Article 15 sits between them — it defines the daily conduct that, if maintained, keeps the contractor on the Register at their classified category, and if breached, triggers the Article 22 penalty machinery.
- It is exhaustive on its face. Eighteen specific obligations, plus a catch-all in 15.18 for further obligations the Committee or Competent Authority may add. There is no ambiguity about what is required — the framework is finite and operationalisable.
- It is mostly checkable. Article 15 obligations either are or are not being met at any given moment. A contractor either holds the criteria of their classified category (15.2), or does not. Either notifies a staff change within 5 working days (15.9), or does not. Either retains 10 years of project documents (15.17), or does not. The binary nature makes Article 15 unusually well-suited to a compliance-tracking platform.
For the framework that sits above Article 15 — registration, classification, and the regularisation deadline — see our Dubai Law No. 7 of 2025 complete guide. For the penalty regime that activates when Article 15 is breached, see our Dubai contractor fines guide.
The legal anchor — Article 15 in plain English
Article 15 of Law No. 7 of 2025 opens with the single sentence: "The contractor must comply with the following". Eighteen numbered obligations follow. Faithfully translated and condensed from the Arabic Gazette text:
- Comply with applicable legislation in the Emirate, including building, planning, environment, public health and safety, and occupational safety laws.
- Maintain all the criteria, conditions, and requirements on which the contractor was classified, throughout the classification period.
- Do not engage any person who is not registered in the Register and does not hold a Professional Competency Certificate.
- Stay within the limits of the contracting activity, the specialty permitted, and the category classified on.
- Do not contract for projects exceeding the contractor's financial, technical, or administrative capacity, or exceeding the technical staff and labour available.
- Appoint competent and qualified technical staff appropriate to the size and nature of projects executed.
- Comply with the provisions and conditions of the contracting contract and instructions of the engineering office designated by the employer.
- Do not exploit the licence, category, or classification to execute fictitious projects for others' benefit, intending personal gain or private interests.
- Notify the Competent Authority of any modifications or changes to the contractor's status or the status of their technical staff within 5 working days of the change.
- Immediately notify the Competent Authority of any modifications or changes to projects being executed, including violations or errors occurring in them.
- Maintain records of technical staff and labour at each project, plus names of any subcontractors engaged, and any other data the Competent Authority specifies.
- Supervise and monitor any subcontractor engaged under the Law.
- Do not advertise or promote the company as a contractor in any form contrary to the Register entry or classified category.
- Enable Competent Authority employees and authorised personnel to enter project sites and offices, and access records necessary for their duties.
- Provide the Competent Authority with any information, data, or statistics it requests, within the dates it specifies.
- Comply with the code of conduct and ethics for practising contracting activities, approved by the Committee.
- Retain originals of contracting agreements, data, records, documents, and drawings related to those contracts for not less than 10 years from the Completion Certificate date or termination of the contract; provide them to the Competent Authority on request.
- Any other obligations stipulated in instructions, decisions, regulations, circulars, or guides issued by the Committee or the Competent Authority.
Grouped into thematic categories, the 18 obligations divide naturally into operational legal compliance, capacity and capability, personnel, notification and reporting, documentation and retention, subcontractor supervision, integrity and advertising, and a catch-all. The sections below walk through each category and the obligations within it.
Operational legal compliance — Obligations 15.1 and 15.7
Obligation 15.1 requires compliance with every applicable law in the Emirate that touches contracting work — building codes, planning regulations, environmental rules, public health and safety statutes, and occupational safety requirements. Law No. 7 does not displace these; it adds to them. A contractor who is fully compliant with Article 14 classification and every other Article 15 obligation can still violate 15.1 by, for example, failing an environmental compliance audit on a specific project.
Obligation 15.7 requires compliance with the provisions and conditions of each contracting contract and with the instructions of the engineering office designated by the employer. This embeds contractual performance into the public-law framework: a contractor who breaches a contract clause is potentially also in breach of Article 15.7, exposing them to Article 22 administrative sanctions in addition to the contract-law remedies the employer pursues separately.
Capacity and capability — Obligations 15.2, 15.4, 15.5, 15.6
Four of the 18 obligations together police the match between what the contractor is classified to do and what they actually take on. Together they are the most frequently breached and most frequently enforced cluster.
Obligation 15.2 requires the contractor to maintain all the criteria, conditions, and requirements on which they were classified, throughout the classification period. Drop below the financial, technical, or administrative thresholds of the classified category and Article 14(d) gives the Competent Authority the right to re-classify the contractor downward. For the full mechanics, see our Dubai contractor classification guide.
Obligation 15.4 is the within-tier rule: the contractor may only practise within the contracting activity, specialty permitted, and category classified on. It is the operational counterpart to Article 14(e). Working a project whose scope ceiling exceeds the classified category is itself an Article 15.4 violation and an Article 5(b) violation simultaneously.
Obligation 15.5 tightens 15.4: the contractor may not contract for projects that exceed their financial, technical, or administrative capacity, or that exceed the technical staff and labour they have available. This closes the loop between classification (what you are permitted to do) and tendering discipline (what you actually bid for). A contractor that wins a tender they cannot resource is in 15.5 breach the moment they sign the contract.
Obligation 15.6 requires the contractor to appoint competent and qualified technical staff appropriate to the size and nature of projects executed. This is the personnel-side capacity rule: even if the contractor has the financial resources, they need the right people for each project. A breach here often manifests as a project under-staffed for the technical complexity it requires.
Personnel — Obligations 15.3, 15.6, 15.14, 15.16
Obligation 15.3 prohibits engaging any person who is not registered in the Register and does not hold a Professional Competency Certificate. This includes engineers and qualified technicians acting in licensed technical roles — they must individually be in the Register and hold a current PCC. For the PCC issuance, renewal cycle, and what happens to the company classification when a key PCC lapses, see our PCC Dubai guide.
Obligation 15.6 (also referenced above) governs the qualitative match between staff and project complexity.
Obligation 15.14 requires the contractor to enable Competent Authority employees and authorised personnel to enter project sites and offices, and to access records necessary for their duties. This is the access obligation that pairs with Article 23's judicial-officer status — together they remove practical barriers to enforcement.
Obligation 15.16 requires compliance with the code of conduct and ethics for practising contracting activities approved by the Committee — the Contracting Activities Regulation and Development Committee established under the Law. The published code is the operational reference; refer to Dubai Municipality and the Dubai Legislation Portal for the current version.
Notification and reporting — Obligations 15.9, 15.10, 15.15
Three obligations together oblige the contractor to keep the Competent Authority informed on different time scales.
Obligation 15.9 is the 5-day rule — covered in detail in the next section.
Obligation 15.10 requires the contractor to immediately notify the Competent Authority of any modifications or changes to projects being executed, including violations or errors occurring in them. "Immediately" is the operative word — there is no specified hour-count but the obligation is clearly tighter than the 5-day rule in 15.9. In practice, a contractor that discovers a violation or error on a project should treat the notification as a same-day task.
Obligation 15.15 requires the contractor to provide the Competent Authority with any information, data, or statistics it requests, within the dates specified. This is a pull-based reporting obligation — when the Competent Authority asks for data, the contractor must deliver it on the deadline given. Common requests include workforce statistics, project execution counts, financial-position confirmations at renewal, and audit-related data.
The 5-day rule — Obligation 15.9 in detail
Obligation 15.9 reads:
Notify the Competent Authority of any modifications or changes that affect the contractor's status or the status of their technical staff, within five (5) working days of the modification or change.
What the rule captures, in practice:
- Ownership or shareholding changes
- Addition or departure of any registered technical staff member
- Material financial-position changes that may affect the classified category's thresholds
- Trade licence amendments — additions or removals of permitted activities
- Office address changes (Ejari renewal or relocation)
- Insurance lapses or material policy changes affecting the contractor's risk profile
- Any change in the basis on which the contractor was registered or classified
Missing the 5-day window is itself an Article 15 violation. The Competent Authority can apply Article 22(a) sanctions for the late notification independently of any sanction for the underlying issue. In other words, a contractor who suffers a key engineer's departure and notifies on day 7 faces TWO potential exposures: (a) the Article 14(d) re-classification if the departure breaks the classified category's staff criteria, and (b) the Article 22(a) fine for the 5-day breach.
Documentation and 10-year retention — Obligations 15.11 and 15.17
Obligation 15.11 requires the contractor to maintain records containing the data of technical staff and labour at each project being executed, plus the names of any subcontractors engaged to execute parts of the works, and any other data the Competent Authority specifies. These records are operational — they exist during execution and are available for on-site inspection under Article 15.14.
Obligation 15.17 is the long-form retention rule:
Retain originals of contracting agreements, data, originals of records, documents, and drawings related to these contracts for a period of not less than 10 years, starting from the date of issuance of the Completion Certificate or the termination of the contracting agreement, and provide them to the Competent Authority on its request.
Three practical implications follow:
- The 10-year clock starts at project end — Completion Certificate date if the project completes, termination date if the contracting agreement ends early. The clock does NOT start at contract signing or project start. A 3-year construction project that completes in 2026 generates documents that must be retained until at least 2036.
- The obligation extends to every project the contractor has executed, not only to currently active ones. A contractor cannot dispose of historical documents simply because the project is complete.
- Documents must be producible on Competent Authority request. Storage practice matters — documents kept somewhere only the original site engineer can find don't satisfy the obligation. A central, searchable, retention-aware document store is the operational answer.
Subcontractor supervision — Obligation 15.12
Obligation 15.12 requires the contractor to supervise and monitor any subcontractor engaged to execute subsidiary works under the Law. It connects to Article 17, which governs the subcontracting itself — the prior approval requirement, the seven conditions for valid subcontracting, and the main contractor's continuing liability for the subcontractor's compliance.
For a complete walkthrough of the Article 17 subcontracting framework, including the seven conditions and main contractor liability rules, see our Dubai subcontractor approval guide. Article 15.12 sits on top of those rules — it adds a positive obligation on the main contractor to actively supervise and monitor, not merely to obtain approval.
Integrity and advertising — Obligations 15.8 and 15.13
Obligation 15.8 prohibits exploiting the contractor's licence, category, or classification to execute fictitious projects for others' benefit, with the intention of obtaining benefits or achieving private interests. This targets the "lending" of a higher-classified contractor's credentials to enable a lower-classified party to take on work they could not lawfully bid for in their own name. It is a serious violation — typically attracting the highest end of the Article 22(a) fine range and frequently combined with Article 22(c) additional measures.
Obligation 15.13 prohibits advertising or promoting the company as a contractor in any form contrary to the Register entry or classified category. Marketing materials that imply a higher tier than the contractor is classified on, or that imply activities the contractor is not licensed to perform, are themselves Article 15.13 violations — independent of whether the contractor actually wins business on the misleading marketing.
The catch-all — Obligation 15.18
Obligation 15.18 binds the contractor to "any other obligations stipulated in instructions, decisions, regulations, circulars, or guides issued by the Committee or the Competent Authority". This is a forward-looking provision — it captures the operational rules the Committee and the Competent Authority issue from time to time under their delegated authority. Contractors should monitor publications from Dubai Municipality and the Dubai Legislation Portal for new circulars and guides; the catch-all means new obligations attach as soon as they are issued.
How Article 15 connects to penalties — Article 22
Breach of any Article 15 obligation triggers the Article 22 enforcement regime. Article 22(a) sets the base fine at not less than AED 1,000 and not more than AED 100,000 per violation, doubled on repeat of the same violation within one year, capped at AED 200,000. Article 22(c) authorises up to five additional administrative measures the Competent Authority may stack on top: suspension up to one year (22(c)(1)), classification downgrade (22(c)(2)), Register removal plus trade licence cancellation (22(c)(3)), technical staff suspension (22(c)(4)), and Professional Competency Certificate cancellation for technical staff (22(c)(5)).
The specific fine for breach of a specific Article 15 obligation is determined by a separate decision of the Chairman of the Executive Council under Article 22(b). The published decision, when issued, is the operational reference for what amount maps to what breach. For the full Article 22 framework, see our Dubai contractor fines guide.
Article 15 during the 8 January 2027 regularisation grace period
A common misreading of Law No. 7 is that the Article 26(a) regularisation grace period — running from the effective date of 8 January 2026 to the regularisation deadline of 8 January 2027 — suspends Article 15 enforcement. It does not. Article 15 has applied in full from the effective date.
What Article 26(a) does is give existing contractors a one-year window to bring their licensing scope, Register entry, classification category, PCC coverage, and operational practices into conformity with the new framework. What it does NOT do is permit new Article 15 breaches during the grace period. A contractor who, during 2026, takes on a project exceeding their classified capacity (15.5), engages a technical staff member without a PCC (15.3), advertises outside their classified category (15.13), or fails to retain project documents (15.17), is committing an Article 15 violation that attracts Article 22 sanctions in full.
For the full Article 26(a) mechanics and how the regularisation grace period interacts with substantive enforcement, see our 8 January 2027 regularisation deadline guide.
How ContractorPass helps you stay compliant
ContractorPass is a compliance management platform built specifically for Dubai contractors operating under Law No. 7 of 2025. Article 15's 18 obligations are the operational backbone of the platform's monitoring features — each obligation maps to a tracked compliance dimension.
- Continuous-criteria monitor (Obligation 15.2) — for each input that drives the contractor's classification (financial thresholds, technical staff count, PCCs, audited financials, project execution history), the platform tracks the live value against the classified category's threshold and alerts before the criteria fall below.
- Tier-fit alerts (Obligations 15.4 and 15.5) — when a tender or project scope appears to exceed the contractor's classified category, the platform flags it before bid submission, preventing the most common high-frequency Article 15 breach.
- PCC coverage map (Obligations 15.3 and 15.6) — for each technical staff member, the current PCC status and renewal date, plus alerts when a key PCC approaches expiry.
- 5-day rule tracker (Obligation 15.9) — when staff or company changes happen, the platform sets a 5-working-day countdown and surfaces the notification task on the dashboard until it is completed.
- 10-year retention vault (Obligation 15.17) — every contracting agreement, drawing, record, and supporting document is stored with its retention clock anchored to the Completion Certificate date, and produced on inspector request.
- Subcontractor supervision log (Obligation 15.12) — for each subcontractor engaged under Article 17, the platform tracks the prior-approval status plus a structured supervision log to demonstrate active monitoring.
- Advertising-fit guard (Obligation 15.13) — automated review of marketing collateral against the Register entry to flag claims that might exceed the classified category.
Start your compliance audit with the free Dubai Contractor Compliance Checklist or begin a 14-day free trial.
Conclusion
Article 15 of Dubai Law No. 7 of 2025 is the operational manual every contractor in the Emirate now operates under. Eighteen specific obligations, each enforceable under Article 22, covering operational legal compliance, capacity match, personnel, notification, documentation, subcontractor supervision, integrity, advertising, and a forward-looking catch-all.
What makes Article 15 manageable is that the obligations are knowable, finite, and checkable. A contractor who systematically tracks the 18 obligations — continuously, not as a year-end audit — faces a containable enforcement risk. A contractor who does not, faces an open-ended one. The contractors who get through the 8 January 2027 regularisation deadline and the years that follow without significant Article 22 sanctions will be the ones who treat Article 15 as the operating system, not the rulebook to consult after something goes wrong.
Official references
- Dubai Official Gazette No. 726/59 — Law No. 7 of 2025 (Arabic legal text)
- Dubai Legislation Portal — where the published code of conduct (Article 15.16) and the per-violation fine schedule (Article 22(b)) are available
- Dubai Municipality — official homepage
- Dubai Municipality — Consultants and Contractors Licensing Standards
- Invest in Dubai — official contractor registration platform
- Dubai Government Media Office — Mohammed bin Rashid issues Law Regulating Contracting Activities
Frequently Asked Questions
What does Article 15 of Dubai Law No. 7 of 2025 actually require?
Article 15 imposes 18 binding obligations on every contractor registered in the Dubai Contractor Register. The obligations span operational legal compliance, continuous-criteria maintenance, technical-staff engagement, project capacity, contract performance, notification and reporting, record-keeping, subcontractor supervision, advertising, authority access, the code of conduct, a minimum 10-year document retention requirement, and a catch-all for further obligations the Committee or Competent Authority may issue.
Which Article 15 obligations carry the highest enforcement risk?
In practice the obligations most likely to attract enforcement action are 15.2 (continuous criteria — falling below the classified category's thresholds triggers Article 14(d) re-classification), 15.4 (staying within the classified activity, specialty, and category — breach is the highest-frequency Article 22 fine), 15.5 (not over-bidding beyond capacity — common with rapid growth), 15.9 and 15.10 (notification deadlines — easy to miss), and 15.17 (10-year retention — frequently the trigger when an inspection discovers gaps).
What is the 5-day notification rule under Article 15.9?
Article 15.9 requires the contractor to notify the Competent Authority — typically Dubai Municipality — of any modifications or changes to the contractor's status or the status of their technical staff within FIVE WORKING DAYS of the change. The rule applies to ownership changes, key technical staff additions or departures, classification-relevant financial changes, and any other change that affects the basis on which the contractor was registered or classified. Missing the 5-day window is itself an Article 15 violation and exposes the contractor to Article 22(a) fines independent of the underlying change.
How long must contractors keep project documents under Article 15.17?
Article 15.17 requires the contractor to retain originals of contracting agreements, supporting data, records, documents, and drawings related to those contracts for a period of NOT LESS THAN TEN YEARS. The 10-year clock starts from the date of the Completion Certificate for the project, or — if the contracting agreement was terminated rather than completed — from the date of termination. Documents must be produced to the Competent Authority on request. This obligation applies to every project the contractor has executed, not only currently active ones.
What happens if I breach an Article 15 obligation?
Article 22(a) of Law No. 7 imposes a financial fine of NOT LESS THAN AED 1,000 and NOT MORE THAN AED 100,000 per violation, doubled on repeat of the same violation within one year, capped at AED 200,000. Article 22(c) authorises five additional administrative measures that may stack on top of the fine: suspension up to one year (22(c)(1)), classification downgrade (22(c)(2)), Register removal plus trade licence cancellation (22(c)(3)), technical staff suspension (22(c)(4)), and Professional Competency Certificate cancellation for technical staff (22(c)(5)). The specific fine for breach of a specific Article 15 obligation is determined by a separate decision of the Chairman of the Executive Council under Article 22(b).
Does Article 15 apply during the 8 January 2027 regularisation grace period?
Yes — fully. Article 15 has applied from the Law's effective date of 8 January 2026, regardless of regularisation status under Article 26(a). The grace period gives existing contractors one year to align their registration, classification, PCC coverage, and operational practices with the new framework — but it does NOT suspend Article 15 enforcement against new violations committed during the grace period. A contractor who, during 2026, takes on a project exceeding their classified capacity (15.5), engages technical staff without a PCC (15.3), or fails to retain project documents (15.17) is committing an Article 15 violation that attracts Article 22 sanctions in full, regardless of their regularisation status.
Who is the Competent Authority that Article 15 notifications go to?
Article 7 of Law No. 7 defines the Competent Authority as the relevant Dubai Municipality directorate, together with any other Dubai government entity legally vested with supervision and oversight of contracting activities for a given specialty. For most general building, MEP, fit-out, and specialist contracting, this is Dubai Municipality's contractor and consultant licensing division, with the Invest in Dubai platform serving as the digital submission channel. For activities in special development zones (e.g., DIFC) the Competent Authority may be a zone authority delegated by agreement under Article 25.
Where can I see the published code of conduct referenced in Article 15.16?
Article 15.16 requires compliance with a code of conduct and ethics for practising contracting activities approved by the Committee — the Contracting Activities Regulation and Development Committee established under Law No. 7. The Committee approves the code; its current published version is available through dm.gov.ae and the Dubai Legislation Portal at dlp.dubai.gov.ae. Contractors should check those sources for the active version, since the code is reviewed and may be amended through Committee resolution.